As a country, Indonesia performs collaboration and cooperation with several countries in the social, economic, political, and tax fields. One of tax cooperation with other countries is the Tax Treaty (P3B).
P3B is formed based on an agreement between two countries/jurisdicates to avoid the imposition of double taxation in two countries. Indonesia has entered into P3B agreements with several countries with the following rates:
|
No |
Country |
BRANCH PROFIT TAX |
DIVIDEND |
INTEREST & ROYALTY |
|||||
|
(BPT) |
|||||||||
|
BPT Rate |
Exception for Company with Profit Sharing Contract (KBH) |
DIVIDEND |
INTEREST |
ROYALTY |
|||||
|
PORTFOLIO |
DIRECT PARTICIPATION |
General Rate |
Special Rate |
General Rate |
Special Rate |
||||
|
1 |
Algeria |
10% |
None |
15% |
15% |
15% |
- |
15% |
- |
|
2 |
Australia |
15% |
Yes |
15% |
15% |
10% |
- |
15% |
10%40 |
|
3 |
Austria |
12% |
Yes |
15% |
10%10 |
10% |
- |
10% |
- |
|
4 |
Bangladesh |
10% |
Yes |
15% |
10%10 |
10% |
- |
10% |
- |
|
5 |
Belgium |
15% |
No |
15% |
15% |
10% |
- |
10% |
- |
|
6 |
Brunei |
10% |
Yes |
15% |
15% |
15% |
- |
15% |
- |
|
7 |
Bulgaria |
15% |
Yes |
15% |
15% |
10% |
- |
10% |
- |
|
8 |
Canada |
15% |
Yes |
15% |
15% |
15% |
- |
15% |
- |
|
9 |
Czech Republic |
12,50% |
Yes |
15% |
10%13 |
12,50% |
- |
12,50% |
- |
|
10 |
China |
10% |
None |
10% |
10% |
10% |
- |
10% |
- |
|
11 |
Denmark |
15% |
Yes |
20% |
10%14 |
10% |
- |
15% |
- |
|
12 |
Egypt |
15% |
Yes |
15% |
15% |
15% |
- |
15% |
- |
|
13 |
Finland |
15% |
Yes |
15% |
10%15 |
10% |
- |
15% |
10%41 |
|
14 |
France |
10% |
No |
15% |
10%16 |
15% |
10%42 |
10% |
- |
|
15 |
Germany |
10% |
No |
15% |
10%17 |
10% |
- |
15% |
10%43 |
|
16 |
Hong Kong |
5% |
Yes |
10% |
5% |
10% |
- |
5% |
- |
|
17 |
Hungary |
None |
None |
15% |
15% |
15% |
- |
15% |
- |
|
18 |
India |
10% |
Yes |
15% |
10%18 |
10% |
- |
15% |
- |
|
- renegotiation (per 2017) |
15%55 |
Yes |
10% |
- |
10% |
- |
10% |
- |
|
|
19 |
Italy |
12% |
Yes |
15% |
10%19 |
10% |
- |
15% |
10%44 |
|
20 |
Iran |
7% |
None |
7% |
7% |
10% |
- |
12% |
- |
|
21 |
Japan |
10% |
Yes |
15% |
10%20 |
10% |
- |
10% |
- |
|
22 |
Jordan |
None |
None |
10% |
10% |
10% |
- |
10% |
- |
|
23 |
Korea, Republic of |
10% |
Yes |
15% |
10%21 |
10% |
- |
15% |
- |
|
24 |
Korea, Democratic People’s Republic of |
10% |
None |
10% |
10% |
10% |
- |
10% |
- |
|
25 |
Croatia |
10% |
Yes |
10% |
10% |
10% |
- |
10% |
- |
|
26 |
Kuwait |
10% |
Yes |
10% |
10% |
5% |
- |
20% |
- |
|
27 |
Luxembourg23 |
10% |
Yes |
15% |
10%22 |
10% |
- |
12,50% |
|
|
28 |
Malaysia |
12.5% |
Yes |
10% |
10% |
10% |
- |
10% |
- |
|
29 |
Morocco |
10% |
Yes |
10% |
10% |
10% |
- |
10% |
- |
|
30 |
Mexico |
10% |
Yes |
10% |
10% |
10% |
- |
10% |
- |
|
31 |
Mongolia |
10% |
Yes |
10% |
10% |
10% |
- |
10% |
- |
|
32 |
Netherlands |
9% |
No |
15% |
10% |
10% |
- |
20% |
- |
|
- renegotiation [1] |
9% |
No |
15% |
10%24 |
10% |
- |
10% |
- |
|
|
- renegotiation [2] |
10% |
None |
|
|
|
|
|
|
|
|
- renegotiation (per 2017) |
10% |
None |
15%54 |
5% |
10% |
5% |
10% |
- |
|
|
33 |
New Zealand |
None |
None |
15% |
15% |
10% |
- |
15% |
- |
|
34 |
Norway |
15% |
Yes |
15% |
15% |
10% |
- |
15% |
10%45 |
|
35 |
Pakistan |
10% |
None |
15% |
10%25 |
15% |
- |
15% |
- |
|
36 |
Philippines |
20% |
None |
20% |
15%26 |
15% |
10%53 |
15% |
- |
|
37 |
Poland |
10% |
Yes |
15% |
10%27 |
10% |
- |
15% |
- |
|
38 |
Portugal |
10% |
Yes |
10% |
10% |
10% |
- |
10% |
- |
|
39 |
Qatar |
10% |
Yes |
10% |
10%10 |
10% |
- |
5% |
- |
|
40 |
Romania |
12,50% |
None |
15% |
12,5%28 |
12,50% |
- |
12,50% |
15%46 |
|
41 |
Russia |
12,50% |
Yes |
15% |
15% |
15% |
- |
15% |
- |
|
42 |
Saudi Arabia8 |
None |
None |
None |
None |
n/a |
n/a |
n/a |
n/a |
|
43 |
Seychelles |
None |
None |
10% |
10% |
10% |
- |
10% |
- |
|
44 |
Singapore |
15% |
Yes |
15% |
10%29 |
10% |
- |
15% |
- |
|
45 |
Slovakia |
10% |
Yes |
10% |
10% |
10% |
- |
15% |
10%47 |
|
46 |
South Africa |
10% |
Yes |
15% |
10%30 |
10% |
- |
10% |
- |
|
47 |
Spain |
10% |
Yes |
15% |
10%31 |
10% |
- |
10% |
- |
|
48 |
Sri Lanka |
sesuai UU domestik |
None |
15% |
15% |
15% |
- |
15% |
- |
|
49 |
Sudan |
10% |
Yes |
10% |
10% |
15% |
- |
10% |
- |
|
50 |
Sweden |
15% |
Yes |
15% |
10%32 |
10% |
- |
15% |
10%48 |
|
51 |
Switzerland |
10% |
Yes |
15% |
10%33 |
10% |
- |
10% |
- |
|
52 |
Syria |
10% |
Yes |
10% |
10% |
10% |
- |
20% |
15%49 |
|
53 |
Taiwan |
5% |
Yes |
10% |
10% |
10% |
- |
10% |
- |
|
54 |
Thailand34 |
based on domestic law |
None |
(RI) 15% |
(RI) 15% |
(RI) 15% |
10% |
10% |
15%50 |
|
55 |
Tunisia |
12% |
Yes |
12% |
12% |
12% |
- |
15% |
- |
|
56 |
Turkey |
15% |
Yes |
15% |
10%35 |
10% |
- |
10% |
- |
|
57 |
U.A.E |
5% |
No |
10% |
10% |
5% |
- |
5% |
- |
|
58 |
Ukraine |
10% |
Yes |
15% |
10%36 |
10% |
- |
10% |
- |
|
59 |
United Kingdom |
10% |
No |
15% |
10% |
10% |
15% |
15% |
- |
|
- renegotiation |
10% |
Yes |
15% |
10%37 |
10% |
- |
15% |
10%51 |
|
|
60 |
United States of America |
15% |
Yes |
15% |
15% |
15% |
- |
15% |
10% |
|
- renegotiation |
10% |
Yes |
15% |
10%38 |
10% |
- |
10% |
- |
|
|
61 |
Uzbekistan |
10% |
Yes |
10% |
10% |
10% |
- |
10% |
- |
|
62 |
Venezuela |
10% |
Yes |
15% |
10%39 |
10% |
- |
20% |
10%52 |
|
63 |
Vietnam |
10% |
Yes |
15% |
15% |
15% |
- |
15% |
- |
|
1 |
other services in the RI-Germany P3B are subject to a 7.5% tax of the fee for technical services (Article 12 RI-Germany P3B) |
||
|
2 |
includes consulting services as regulated in Article 5 paragraph 5 P3B RI-Japan |
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|
3 |
other services in the RI-Pakistan P3B are subject to a 10% tax of the fee for technical services (Article 12 RI-Luxembourg P3B) |
||
|
4 |
other services in the RI-Pakistan P3B are subject to a 15% tax of the fee for technical services, including managerial services, technical services and consulting services (Article 13 RI-Pakistan P3B) |
||
|
5 |
to determine the occurrence of BUT, no time test is needed |
||
|
6 |
tax on consulting and other services in the RI-Switzerland P3B is subject to a 5% tax of the total gross payment (Article 13 RI-Switzerland P3B) |
||
|
7 |
in the case of fees for technical assistance covering the provision of all kinds of services including consulting services, managerial services and technical services related to technical knowledge, experience, skills, methods or processes, but does not include payment for professional services as referred to in Article 15 P3B RI-Venezuela is subject to tax 10% of the gross amount of payment (Article 12 P3B RI-Venezuela) |
||
|
8 |
specifically for Saudi Arabia, P3B only covers International Traffic |
||
|
9 |
as long as the order represents more than 60% of its business turnover |
||
|
10, 14, 15, 17, 19, 21, 22, 24, 32, 33, 35, 36, 38 |
applies if the dividend recipient is a company (other than a partnership) that has a direct capital of at least 25% the dividend paying company |
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|
11, 12, 16, 25, 26, 28, 29, 31 |
applies if the dividend recipient is a company that has a direct capital of at least 25% the dividend paying company |
||
|
13 |
applies if the dividend recipient is a company that has a direct capital of at least 20% the dividend paying company |
||
|
18 |
applies if the dividend recipient is a company that owns at least 25% shares in the dividend paying company |
||
|
20 |
applies if the dividend recipient is a company that owns at least 25% shares in the company payingdividend within 12 months immediately before the end of the accounting period where the profit is distributed |
||
|
23 |
applies if the dividend recipient is a company that has at least 20% capital in the dividend paying company |
||
|
27 |
applies if the dividend recipient is a company that has a direct capital of at least 20% the dividend paying company |
||
|
30 |
applies if the dividend recipient is a company that has a direct capital of at least 10% the dividend paying company |
||
|
34 |
In the RI-Thailand P3B, there are differences in determining the tax rate on dividend for Indonesia and for Thailand, see explanation |
||
|
37 |
applies if the dividend recipient is a company that controls at least 15% of direct or indirect decision making in the dividend paying company |
||
|
39 |
applies if the dividend recipient is a company (other than a partnership) that has a direct capital of at least 10% in the dividend paying company |
||
|
40 |
royalties for the use of and the right to use industrial, commercial and scientific equipment, the acquisition of information or knowledge in a scientific, technical or commercial field |
||
|
41 |
10% rate for the use or right to use, any copyright in the field of literature, artistic or scientific works including cinematographic films, and films or recording tapes for television or radio broadcasting; |
||
|
42 |
there is a difference in tax rates on interest in the RI-France P3B, see the explanation section |
||
|
43 |
there is a difference in tax rates on royalty in the RI-Germany P3B, see the explanation section |
||
|
44 |
there is a difference in tax rates on royalty in the RI-Italy P3B, see the explanation section |
||
|
45 |
there is a difference in tax rates on royalty in the RI-Norwegia P3B, see the explanation section |
||
|
46 |
there is a difference in tax rates on royalty in the RI-Rumania P3B, see the explanation section |
||
|
47 |
there is a difference in tax rates on royalty in the RI-Slovakia P3B, see the explanation section |
||
|
48 |
there is a difference in tax rates on royalty in the RI-Sweden P3B, see the explanation section |
||
|
49 |
there is a difference in tax rates on royalty in the RI-Syria P3B, see the explanation section |
||
|
50 |
there is a difference in tax rates on interest and royalty in the RI-Thailand P3B, see the explanation section |
||
|
51 |
there is a difference in tax rates on royalty in the RI-United Kingdom P3B, see the explanation section |
||
|
52 |
there is a difference in tax rates on royalty in the RI-United States of America P3B, see the explanation section |
||
|
53 |
there is a difference in tax rates on interest in the RI-Philippines P3B |
||
|
54 |
there is a difference in tax rates on dividend in the RI-Netherlands P3B |
||
|
55 |
Indonesian-sourced profits earned by Indian residents from the operation of ships in international traffic may be taxed in Indonesia, but the tax imposed is reduced by 50% |
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